U.S. Court of Appeals for the Ninth Circuit, 2011

Ioane v. Commissioner of Internal Revenue

Ioane v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Ninth Circuit · Decided March 4, 2011 · Canby, Fernandez, Smith
418 F. App'x 636

Ioane v. Commissioner of Internal Revenue

Opinion

MEMORANDUM **

Michael Ioane appeals pro se from the tax court’s order dismissing his petition contesting the Commissioner of Internal Revenue’s Notice of Determination concerning income tax liabilities for tax years 1998 through 2002. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo. Suter v. Goedert, 504 F.3d 982, 985 (9th Cir. 2007). We affirm.

The tax court properly dismissed Ioane’s petition on the ground of mootness, because there was “‘no effective relief remaining for [the] court to provide’ ” after the Internal Revenue Service rescinded the notice of intent to levy and withdrew the tax liens. Id. at 986 (citation omitted).

Ioane’s remaining contentions are unpersuasive.

AFFIRMED.

**

This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3.

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